Organic and Wild: A New Level of Standards

Over the last 30 years I have been intimately involved in the organic food industry at all levels, from production to wholesaling and retailing, primarily within the consumer cooperative movement. For the past decade I have also served on the board of Organic Growers and Buyers Association (OGBA), one of the oldest organic certification agencies in the country. Last year, as board chair, I watched with keen interest the development of standards and certification procedures for wild fish. Here is why I am so excited about this development.

First, the new wild fish standards address the widespread criticism that organic certification does not guarantee sustainability. These critics are right -- most current standards do not address the overall sustainability of production methods, unlike the Demeter biodynamic label and some of the new sustainable farming certification initiatives.

The strict organic fish standards developed by OGBA include the requirement of scientifically demonstrated sustainability in addition to meeting other standard organic requirements. I believe that these new wild fish standards will be the first of a whole new generation of organic standards that will explicitly require proof of ecological sustainability. This move to strengthen and "raise the bar" on organic standards is an extremely important counterforce to the general lowering of standards that has resulted from globalization and homogenization.

A second reason I am excited about this development is that it creates, for the first time, a way for indigenous (Native American, Inuit, and First Nations) people to become involved in the organic industry in a significant way. Wild harvested foods have been a relatively undeveloped part of the industry until now. Indigenous fishers around the Great Lakes are exploring ways they can participate, while Native Alaskan fishers have already benefited from organic certification.

Third, these new labels address one of the most important new concerns of consumers -- the arrival of genetic engineering (GE). The certified organic label is the only way shoppers can know that the fish they are buying are not genetically engineered.

Fourth, many organic shoppers want to increase their consumption of fish for health reasons but have been reluctant because they often do not know if the fish in their favorite stores are factory fish produced with doses of drugs and pesticides or are contaminated with heavy metals. With organic standards and certification, they can now buy with confidence.

Finally, organic wild fish can help in the battle against over-fishing and ecologically disastrous industrial fish factories. Organic labeling makes it possible for consumers to support, with their dollars, smaller, ecologically sound fishers. If nature-friendly producers cannot survive economically, then industrial fish farms and large multinational corporations will argue the inevitability of their approach.

Certification concerns

As exciting as this new development may be, it has not been without controversy. For example, some in the industrial fish sector want to keep the term organic only for farmed fish, and have therefore objected to its use for wild fish. Some industrial fish farmers argue that wild fish should not be labeled organic since we do not know where exactly where it has been all of its life. They are raising an important point that the entire organic industry needs to deal with at some point in the near future -- the lack of control over where organic food has been once it has left the farm with a certified label on it. Almost all organic food travels from field to store without any oversight or regulation whatsoever and then is handled by wholesalers, retailers, or restaurants who are not (with only a couple of exceptions) certified or inspected. This lack of quality assurance is not tolerated in other environmental labeling schemes, such as the wood products certification program of the Forest Stewardship Council.

More criticism has come from veterans in the organic movement itself. In the July/August edition of Cooperative Grocer Cissy Bowman raised a number of concerns that I wish to address.

First, she claims that "on land, we know where an animal goes to feed and what it eats, but for fish swimming through the ocean this is impossible." For certified organic cattle and sheep that roam and graze over large areas of western range lands, we do not know exactly where they go to feed or what they eat. If we are to follow her logic, meat from livestock produced in an ecologically sound way and all honey would be banned from organic certification.

A second criticism was that since wild fish are not "produced" they should be excluded from organic certification -- arguing there must be a "production method" for a product to be certified organic. She is arguing that wild products are organic by neglect. The Alaskan project and other sites have shown me that the opposite is true. Managing for sustainability, including keeping habitat healthy and waters clean requires a great deal of effort and long-term commitment, just like organic farming. If we followed Ms. Bowman's logic on this then Brazil nuts gathered by indigenous people from the floor of the rainforest could not be organic but those produced by a brazil nut tree plantation could be. I do not think most consumers would agree, and I know that the board of directors of OGBA does not.

Her third criticism is actually a question: "Is the rush to have certified organic wild-caught fish really about proving the product meets the requirements for certification, or is it just a marketing plug?" I find this question disturbing on many levels. First, it took almost two years to develop standards and then go through the entire process of inspection, evaluation, and eventual certification. How she can describe this as a rush is not clear to me. She implies that the certified fish did not meet the existing standards. This suggestion is simply not true, and I believe it deserves some explanation.

Another very serious concern raised by Ms. Bowman is her fear that the "wild-caught fish issue has the potential to divide the organic industry." I completely agree. I have been shocked by the attacks on OGBA over this issue. If the critics continue, it will surely divide us at a time when very serious issues, such as the corporatization and monopolization in the industry, need serious attention.

Ms. Bowman also objects to the use of organic certification as a marketing tool. I have to admit that I just do not understand this concern. For OGBA, our primary concern is understanding and meeting consumer expectations. We did not invest all of the time and resources to create these standards as a marketing tool, but we fully expect that anyone who meets our standards and goes through our certification process will market their products as aggressively as possible. Organic certification is many things, including a marketing tool. Unless there is a way to connect with consumers through marketing, organic food production would be lost forever.

Organic fish certification will grow rapidly because consumers want the assurance that comes when organizations like OGBA establish organic standards and then conduct rigorous inspections and certifications. Fish are not cows, nor are they honey bees. At OGBA, we have spent over 25 years digging deeply into every product category to find out what consumers expect and what research tells us is the best path to organic. We have consistently rejected any "one-size fits all" standard.

I very much appreciate the effort that Ms. Bowman and the Organic Farmers Marketing Association have made on behalf of family farmers. I hope that the efforts of family fishers to meet high consumer expectations of their products can be seen as mutually supportive.

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Mark Ritchie is the board president of Organic Growers and Buyers Association and President of the Institute for Agriculture and Trade Policy; he can be reached by fax at 612-870-4846 or by email at [email protected].

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By Cissy Bowman

Mr. Ritchie raises some good points about the positive qualities of wild-caught fish. However, these points fall short of proving that wild-caught fish are certifiably organic under the standards outlined in the Organic Foods Production Act (OFPA).

As much as we all would a like to see a law that guarantees sustainability -- economic or otherwise -- that concept is outside of the scope of the OFPA. And the concept that "organic labeling makesit possible for consumers to support, with their dollars, smaller, ecologically sound fishers" indicates that the only way to inform consumers about the positive qualities of wild-caught fish is to call it organic. Proactive educational efforts and informative labeling can accomplish this goal as well.

Mr. Ritchie states: "Many organic shoppers want to increase their consumption of fish for health reasons but have been reluctant because they often do not know if the fish in their favorite stores are factory fish produced with doses of drugs and pesticides or are contaminated with heavy metals. With organic standards and certification, they can now buy with confidence." As an owner of an organic farm, director of a buyer's cooperative, and chair of the Indiana Organic Program, I get calls and hear input from consumers every day. In meetings and conversations I have heard consumers express extreme concern about the potential contamination of ocean or lake-caught fish. Simpy putting an "organic" label on it won't make it organic -- though good standards, applied to the production and handling of fish, can. Those standards, however, need to be written to be consistent with other organic livestock standards, which include controls and management that are much more difficult to apply to wild-caught animals.

Under most certifiers' standards, organic livestock is to be fed 100% organic feed and grazed on certified organic land. Land can be observed for three years and monitored to prove that prohibited substances are not being applied. Animals can be tagged and traced. Bee hives can be placed on organic farms and provided enough forage to keep them at "home" if the farm is large enough and adequate feed is provided. It is the producer's responsibility to assure the certifier that he or she has access to sufficient organic resources to provide feed to the animal. I am not arguing that wild products are "organic by neglect," but that if they are to be called organic there has to be oversight of the animal as well as the area on which the animal roams and feeds.

OFPA speaks directly to this:

OFPA 2114 ORGANIC PLAN.

(A) MANAGEMENT OF WILD CROPS. An organic plan for the harvesting of wild crops shall:

(1) designate the area from which the wild crop will be gathered or harvested;

(2) include a 3 year history of the management of the area showing that no prohibited substances have been applied;

(3) include a plan for the harvesting or gathering of the wild crops assuring that such harvesting or gathering will not be destructive to the environment and will sustain the growth and production of the wild crop; and

(4) include provisions that no prohibited substances will be applied by the producer.

Wild-harvested fish fall short of meeting (2) unless there is proof that no prohibited substances are applied (or dumped) into the area the fish swim. Perhaps this standard can be met by some fishermen in some areas--but the burden is on them to prove they meet the standard.

In several NOSB meetings a group from Alaska gave lengthy input about wild-caught salmon and the state's desire for it to carry the organic label. We heard about the product's purity and healthfulness, its sustainable harvest methods, its pristine waters, and how the organic label would make it more marketable. NOSB asked the representatives why not certify it as "sustainably harvested" or "pure" or any other of those words.

Their response was not a description of how the salmon's production fit into current organic livestock standards, but "We want the organic label." Organic labels are marketing tools, indeed. But the development of a detailed organic wild-caught aquaculture standard that is consistent with OFPA and with other organic livestock standards needs to be done before we start selling "organic" fish. We need to bring the product up to the standard or ensure that it currently meets the standard, not create a standard based on the current status of the product. Currently USDA is working on a Proposed Organic Aquaculture Rule. I hope the public will once again speak loudly about what they want the organic wild-caught fish label to mean.

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Update on proposed Rule: At this time USDA is reviewing the 41,000 public comments received. The Final Rule (not including aquaculture standards) is expected to be published by the end of 2000.